In a significant development, the Reserve Bank of India (RBI) has introduced comprehensive guidelines pertaining to Information Technology (IT) governance for regulated entities (REs). These REs encompass a wide spectrum of financial institutions, including banks, non-bank financial companies, and credit information companies. These guidelines, scheduled for implementation starting April 1 next year, impose the requirement for REs to establish a robust IT governance framework.
Central to the new regulations is the establishment of a board-level IT Strategy Committee (ITSC). This committee will be headed by an independent director and will consist of three additional directors. Notably, the chairperson of the ITSC must be an independent director with substantial IT expertise to steer and guide IT initiatives effectively. The primary objective of this committee is to ensure the implementation of a sound IT strategic planning process and to offer guidance in preparing the IT strategy. Moreover, the IT strategy must be in alignment with the overall strategic goals of the RE in order to accomplish its business objectives.
Furthermore, the guidelines mandate REs to institute an IT Steering Committee, which will have representation at the senior management level from both IT and business functions. This committee will work in tandem with the ITSC to facilitate strategic IT planning, oversee IT performance, and ensure that IT activities are aligned with business requirements. It will also supervise the processes related to business continuity and disaster recovery, ensuring the implementation of a robust IT architecture that complies with statutory and regulatory requirements.
As per the guidelines, REs must appoint a highly qualified and experienced IT professional at a sufficiently senior level to lead the IT function. This individual will serve as the first line of defense, responsible for assessing, evaluating, and managing IT controls and IT risks. They will also oversee the implementation of rigorous internal controls to safeguard the information assets of the RE and ensure compliance with internal policies, as well as regulatory and legal requirements concerning IT-related aspects.
Moreover, the guidelines prescribe the establishment of a robust IT service management framework for REs to support their information systems and infrastructure. This framework is crucial for ensuring the operational resilience of the entire IT environment of these entities.
Notably, the guidelines specify that every IT application with the potential to access or impact critical or sensitive information must possess the necessary audit and system logging capabilities. These capabilities are designed to provide comprehensive audit trails, which not only meet the business requirements of the RE but also fulfill regulatory and legal prerequisites. These detailed audit trails play a vital role in facilitating audits, serving as forensic evidence when required, and aiding in dispute resolution, including for non-repudiation purposes.